Flares are essential to many industrial operations due to their ability to safely combust the release of undesirable or excess combustible gases. Nevertheless, there is no common approach to the practice of flaring in terms of guidelines or international best practices.
Recently, however, flares are finding their way to the top of EPA’s list of priorities—including a National Enforcement Initiative, Consent Decrees, NSPS Subpart Ja, and potential new EPA Uniform Standards.
From the facility shop floor to corporate boardrooms, Sage has amassed years of experience in flare system management and consent decree negotiations. With the recent EPA crack-down on flaring, we offer unmatched insights on the fundamentals of flares and the intricacies of new flaring regulations. Our focus is on helping facilities comply with current flare regulations, implement Consent Decrees provisions, and optimize flare system performance.
Sage provides four basic types of services to both national and international facilities to meet your flaring needs: monitoring, mapping, minimization, and management.
All flare systems are unique and require case-by-case consideration. Monitoring key operational parameters is essential, yet monitoring techniques, such as gas flow and composition, present challenges. Controlling or adjusting flare system performance in real-time based upon these monitoring points adds even greater complexity.
Effective monitoring and process control allows a facility to identify, respond to, and correct most flaring activities. Monitoring also ensures proper flare operation and provides reliable data for emissions calculations. A rigorous flare monitoring and reporting program is integral to a facility’s ability to reduce flaring to the maximum extent possible.
Sage typically monitors the following key parameters:
- Vent gas stream flow rate and composition
- Assist gas flow rate
- Supplemental or purge gas flow rate
- Pilot flare presence
- Water seal level indication
Improving the reliability, completeness, and accuracy of flare data promotes flare reduction activities and prioritizes potential future investments. Sage assesses the current state of a facility’s monitoring plan and offers suggestions for improvement. We look at the following to determine the status of each flare monitoring program:
- Proper installation and location of monitoring instrumentation
- Determination of compliance with applicable regulations
- Incorporation of monitored data into the Distributed Control System (DCS)
- Enhanced control strategies
- Comparison of current monitoring techniques to anticipated future requirements
Flare Header Mapping
Flare header mapping is an assessment technique used to identify potential sources of contribution to a flare header system. The first step in identifying streams for potential minimization or recovery involves a detailed “Contributions Analysis” composed of:
- Detailed review of P&IDs and PFDs
- Assessment of PRVs, control valves, gate valves, sweep gas flows, analyzer flows, etc.
- Consideration of all operating modes
- Routine operations
- Major turnaround
- Emergency situations
We then document the data in the Flare Documentation, Minimization, and Analysis Tool (DMAT), a resource Sage developed to systematically assess, qualitatively categorize, and rank various process-related contributions to the flare header.
After reviewing the flare monitoring program and conducting flare header mapping, Sage assesses the data and options available for a facility to reduce the amount of generated flare gas or the frequency and duration of flaring incidents.
We achieve flare minimization by focusing on the following two strategies:
- Optimize or install fuel gas recovery (FGR) system
- Beneficially increase the consumption of recovered fuel gas
- Develop and implement operational procedures to maximize gas recovery
- Redirect gases away from the flare header back into the process
- Reduce valve leak rates by implementing administrative programs, such as PRV leakage surveys
- Balance fuel gas system
Reducing contributions to the flare header
NSPS Ja contains work practice provisions that are applicable to refinery flares. On September 12, 2012, the revised NSPS Ja standards were published in the Federal Register including new work practice standards and applicability triggers for flares. The regulatory effective date for NSPS Ja is November 13, 2012.
Sage incorporates all of our flare services into one complete Flare Management Plan (FMP) to satisfy compliance with NSPS Ja or local rules (such as the AQMDs in California).
Although it is currently not required for non-refinery industries to develop an FMP, a similar plan is highly recommended to optimize each flare system’s performance and increase combustion efficiency.
The FMP includes the following:
- Minimization assessment of all contributions to the flare header during normal operations and planned startup and shutdown
- Description of monitoring instrumentation and flare system parameters and specifications
- Evaluation of the baseline flow to the flare
- Assessment of fuel gas system balancing
- Minimization of FGR system outages
- Development of procedures to conduct a Root Cause Analysis (RCA) and implement corrective actions after a triggering flaring event
Did You Know...
That Sage uses FLIR cameras to qualitatively analyze combustion efficiency.
Our extensive knowledge of emerging technologies enables us to regularly recommend or suggest monitoring and minimization strategies to optimize facilities’ flare systems.